Income Tax - Advanced Planning Strategies

Overview:

Like a tightrope walker demonstrating exquisite balance, income tax planning requires practitioners to help clients pay the lowest amount of tax while staying on the right side of the law and within the guidelines of the Income Tax Act (ITA).  This practical in-depth course provides a comprehensive review of various anti-avoidance provisions designed to prevent or discourage aggressive tax planning through the presentation of factual scenarios that address objectives, statutory provisions, current case law, and risk analysis. The course will enable you to understand and identify various tax planning opportunities for your clients while navigating the application of various anti-avoidance provisions in the ITA.

This course is structured for practitioners with a strong Canadian tax planning background seeking to keep abreast of tax and estate planning issues. The course identifies tax-planning opportunities that are particularly relevant to practitioners working with Canadian private corporations, Canadian partnerships, and high net worth individuals.  The course utilizes practical examples to present planning opportunities with respect to restructuring of asset profiles, the sale of a business, business succession and estate planning, as well as the use of partnerships and trusts.  The course will also provide a high-level review of anti-avoidance provisions frequently encountered in the context of these plans, primarily in the context of specific plans or examples.

Course Content:

In this course, you will gain knowledge about the following topics:

• Managing tax avoidance risks, including the following:
  • General anti-avoidance rule
  • Arm’s length relationships
  • Planning for Tax on Split Income
  • Attribution provisions
  • Stop-loss provisions
  • Surplus stripping (Section 84.1) in factual non-arm’s length circumstances
  • Subsection 55(2)
• Five categories of tax planning strategies: restructuring asset profiles, sale of a business, use of partnerships, use of trusts, and general tax planning for private corporations and their shareholders
• Interprovincial planning

Learning Objectives:

Upon completing this course, you should be able to:

• Identify and analyze tax risks in a variety of tax and estate planning scenarios
• Identify tax planning opportunities for individuals, corporations, trusts, and partnerships, particularly within the private corporation sphere
• Identify relationships between individuals, corporations, trusts, and partnerships and analyze how those relationships affect the tax implications of various transactions
• Compare the tax impact of various structures available to achieve a client’s business or estate planning objectives

Who Will Benefit: 

This course will advance the skills and knowledge of public practitioners specializing in Canadian tax planning and seeking to refine advanced tax and looking to enhance their tax, business succession and estate planning skills.  This course will also benefit industry practitioners working for Canadian private corporations.